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assessed the correct amount. The couple later separated, and Ms.
Goode-Parker has petitioned for innocent spouse relief. Whether
we have jurisdiction turns on whether the Commissioner’s
correction of the couple’s mistake was the assertion of a
deficiency.1
Background
The marriage of Annette Goode-Parker and Marvin Parker began
in 1984. Both were recent graduates of Howard University’s
School of Law, and they started their life together by moving to
southern California. In 1989, after working at a law firm and
then the Equal Employment Opportunity Commission, Ms. Goode-
Parker began her current career as a legal analyst in the
California Department of Justice, specializing in consumer and
antitrust law. Although she did not testify at length about her
husband’s employment, she did say that in 1992 or 1993 he left
his “regular job” to open a solo practice.
Her husband’s new practice was not immediately successful,
and the resulting financial stress began fracturing their
marriage. They soon found themselves battling the foreclosure of
their home. They lost that fight and in 1995 moved into a
condominium.
1 Ms. Goode-Parker chose to have her case tried as a small
tax case under section 7463 of the Internal Revenue Code.
(Section citations are all to that Code.) That means that our
decision is not reviewable by any other court, nor may it be
treated as precedent in any other case.
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Last modified: May 25, 2011